Lam v. State of Hawai'i Office of Elections

CourtHawaii Supreme Court
DecidedAugust 29, 2022
DocketSCEC-22-0000500
StatusPublished

This text of Lam v. State of Hawai'i Office of Elections (Lam v. State of Hawai'i Office of Elections) is published on Counsel Stack Legal Research, covering Hawaii Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Lam v. State of Hawai'i Office of Elections, (haw 2022).

Opinion

Electronically Filed Supreme Court SCEC-XX-XXXXXXX 29-AUG-2022 08:52 AM Dkt. 15 FFCL

SCEC-XX-XXXXXXX IN THE SUPREME COURT OF THE STATE OF HAWAI#I

ADRIEL LAM, Plaintiff, vs. STATE OF HAWAI#I, OFFICE OF ELECTIONS, Defendant.

ORIGINAL PROCEEDING FINDINGS OF FACT, CONCLUSIONS OF LAW, AND JUDGMENT (By: Recktenwald, C.J., Nakayama, McKenna, Wilson, and Eddins, JJ.)

On August 18, 2022 Plaintiff Adriel Lam (Lam) filed a

letter, which we construe as an election complaint, as well as

documents attached and submitted in support. On August 23, 2022

Defendant State of Hawai#i Office of Elections (Office of

Elections) filed a motion to dismiss. On August 25, 2022, Lam

filed a “Memorandum; Objection to Defendant’s Motion to Dismiss

and in Support of Motion for Hand Recount” (objection). Upon

consideration of the complaint, motion to dismiss, and objection,

and having heard this matter without oral argument, we enter the

following findings of fact, conclusions of law, and judgment.

FINDINGS OF FACT

1. Lam was one of two Primary Election Republican Party candidates in the Senate District 24 race.

2. The 2022 Primary Election was held on August 13,

2022.

3. Following a mandatory recount, the election result

for this race was, as follows:

Fernandez, Antionette 1,490 Lam, Adriel C 1,446 Blank votes 787

4. The election result was later updated on August

22, 2022, with the following result that included the last

ballots validated by the City Clerk for the City and County of

Honolulu:

Fernandez, Antionette 1,513 Lam, Adriel C 1,474 Blank Votes 800

5. On August 18, 2022, Lam filed a letter seeking to

file a complaint under Hawai#i Revised Statutes (HRS) § 11-172

(Supp. 2021), which requests the following relief:

(a) That an order be issued requiring a halt in

the certification of the 2022 Primary Election so that a manual

recount may be conducted of the 2022 Republican Party Senate

District 24 Primary Election race; and

(b) An order requiring certain requests be

granted “to restore public confidence and assurances regarding

the integrity of Hawaii elections and reduce vulnerability to

election and voter fraud” that include maintenance of the voter

2 rolls, voter education, certain ballot handling procedures, an

adequate elections budget, increased access to voting to increase

voter participation, and preserving all elections records from

the “2020 General Election” beyond the federally mandated twenty-

two month retention period to improve transparency and access to

public records.

6. Lam asserts a lack of transparency during the

mandatory recount process, lack of resolution on certain election

integrity inquiries, and pending final ballot counts support his

requested relief.

7. With regard to his assertion that there was a lack

of transparency during the mandatory recount process, Lam

recounts his observations and interactions with the Office of

Elections during the mandatory recount process, including the

lack of a response from the Office of Elections during the

mandatory recount process.

8. With regard to his concern about the lack of

resolution on certain election integrity inquiries, Lam asserts

there were many deficiencies concerning: (a) a Manual Audit

Certification that was raised regarding the 2020 General

Election; (b) cybersecurity threats from foreign and other non-

state threats to alter the election results to conform to their

interests; (c) maintenance of the voter registration rolls in

light of a “specific case of a registered voter” in the 2020

3 General Election; and (d) various aspects with elections by mail.

9. With regard to his assertion that a pending final

ballot count supports his requested relief, Lam attached an email

dated August 17, 2022, from the Office of the City Clerk of the

City and County of Honolulu that states the “number of ballots

that still need to be verified is approximately 3,700[,]” and the

“number of ballots pending verification for Senate District 24 is

235.” He also asserts there were 34,559 ballots received on

August 14, 2022, that “could have met the deadline for receipt by

7 p.m., Aug 13, 2022,” if receipt of these 34,559 ballots were

recorded in Greenwich Mean Time (GMT) because Hawai#i standard

time is ten hours behind GMT.

10. Lam cites Hawai#i Revised Statutes (HRS) § 11-172,

as well as HRS §§ 11-109 (Supp. 2021), 16-42 (2009), and 19-3

(Supp. 2014), in support of his assertions and requested

remedies.

11. The Office of Elections asserts that the complaint

should be dismissed with prejudice.

12. Lam’s objection asserts that “[a] manual recount

is in order and the motion to dismiss should be overruled.”

CONCLUSIONS OF LAW

1. HRS § 11-172 governs election contests and

provides in relevant part: “With respect to any election, any

candidate, or qualified political party directly interested, or

4 any thirty voters of any election district, may file a complaint

in the supreme court. The complaint shall set forth any cause or

causes, such as but not limited to, provable fraud, overages, or

underages, that could cause a difference in the election

results.”

2. HRS § 11-173.5 (2009 & Supp. 2021) provides for

contest for cause to be filed in the supreme court involving

primary elections, special primary elections, and county

elections held concurrent with a regularly scheduled primary or

special primary election.

3. A complaint challenging the results of a primary

election fails to state a claim unless the plaintiff demonstrates

errors, mistakes, or irregularities that would change the outcome

of the election. See HRS § 11-172; Tataii v. Cronin, 119 Hawai#i

337, 339, 198 P.3d 124, 126 (2008); Akaka v. Yoshina, 84

Hawai#i 383, 387, 935 P.2d 98, 102 (1997); Funakoshi v. King, 65

Haw. 312, 317, 651 P.2d 912, 915 (1982); Elkins v. Ariyoshi, 56

Haw. 47, 48, 527 P.2d 236, 237 (1974).

4. A plaintiff challenging a primary election must

show actual information of mistakes or errors that would have

changed the election result. Tataii, 119 Hawai#i at 339, 198

P.3d at 126; Funakoshi, 65 Haw. at 316-17, 651 P.2d at 915.

5. For a complaint to be legally sufficient, it must

“show[] that the specific acts and conduct . . . complain[ed of]

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Related

Estate of Doe v. Paul Revere Insurance Group
948 P.2d 1103 (Hawaii Supreme Court, 1997)
Funakoshi v. King
651 P.2d 912 (Hawaii Supreme Court, 1982)
Elkins v. Ariyoshi
527 P.2d 236 (Hawaii Supreme Court, 1974)
Tataii v. Cronin
198 P.3d 124 (Hawaii Supreme Court, 2008)
Akaka v. Yoshina
935 P.2d 98 (Hawaii Supreme Court, 1997)
Foytik v. Chandler
966 P.2d 619 (Hawaii Supreme Court, 1998)

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